Data Protection Policy

1. General

• CDMS is registered under the Data Protection Act as a Data Controller. The Act imposes a number of conditions relating to the collection and usage of personal data. Personal data is information which relates to living individuals and includes data held electronically and or in manual files.

• The Act places specific responsibilities on the Data Controller and its staff. Non- compliance may lead to prosecution. Staff must therefore ensure that the collection, holding, use and disclosure of personal data for which they have responsibility is in accordance with the Company's Registrations and the Data Protection Principles.

• To ensure that an appropriate level of security is maintained a number of Policy Rules must be obeyed. Regular monitoring of the rules will take place and any breach or suspected breach will be investigated and may lead to disciplinary action being taken.

Data Protection Compliance

• The Quality Manager will advise on Data Protection Compliance.

• The Quality Manager is responsible for co-ordinating and maintaining the Company's Data protection registration.

• Line management are responsible for ensuring that staff understand and carry out their responsibilities under the Act

• Members of staff are responsible for informing the Quality Manager of any new uses, or amendments to existing uses, of personal data.

• Computer printouts and media containing personal information must be secured out of business hours and or when not in use.

• Personal information must not be disclosed to unauthorised persons.

• Correspondence received from members of the public and or staff requesting information under the Data Protection Act or making any reference to the Act in regard to JCM-Media Limited or CDMS, must immediately be forwarded to the Quality Manager.

• Every employee must understand and sign the Data Protection Annual Agreement form. HR Dept will maintain appropriate records to this effect.

Data Protection Principles

• All staff must comply with the eight (8) Data Protection Principles and observe any instructions issued by CDMS in relation to the use(s) of personal data registered by the Company.

The Principles require that:

1. Personal data shall be processed fairly and lawfully and, in particular, shall not be processed unless:

• (a) at least one of the conditions in Schedule 2 is met, and;
• (b) in the case of sensitive personal data, at least one of the conditions in Schedule 3 is also met.

Copies of Schedule 2 and 3 can be obtained from IT Services or from the HMS online website: http://www.hmso.gov.uk/acts/acts1998/19980029.htm

2. Personal data shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes.

3. Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.

4. Personal data shall be accurate and, where necessary, kept up to date.

5. Personal data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6. Personal data shall be processed in accordance with the rights of data subjects under this Act.

7. Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.

8. Personal data shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.